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2016 (1) TMI 328 - SCH - Income TaxDeemed dividend u/s 2(22)(e) - Apex Court dismissed the revenue appeal after condoning the delay against the decision of HC [2015 (3) TMI 767 - DELHI HIGH COURT] wherein HC hald that, Loan to the assessee and the loan (in the form of credits in favour of SISICOL) were really one transaction. It is also a matter of record that the firm had over 290 branches or units and collection by it exceeded- on an average ₹ 10 crores per month. Therefore, it could not be legitimately held that amount retained by the firm was for the assessee’s benefit. The amount of ₹ 1,84,19,305 was not deemed dividend in the hands of the assessee under the provisions of Section 2 (22) (e) of the Income Tax Act, 1961.
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